TAXPAYERS RECEIVE FRAMEWORK FOR ACTION
Since 2020, there has been uncertainty, particularly at the level of internationally active groups, regarding the taxation of the licensing of rights, which are (also) registered in Germany, such as trademark rights, patents or -generally- intellectual property. Even in otherwise purely foreign situations (both foreign licensor and foreign licensee), German withholding taxes are to be withheld. Although the BMF circular of 11 February 2021 does not clarify all questions, it does at least allow for a certain procedural relief if action is taken in accordance with the BMF circular by 31 December 2021.
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